We supply to some manufacturer who prepare gluten free product . As an Ingredient company we do not label gluten free and our specification does speak about it that the gluten product are stored on site unopened but can not be classified as gluten free and anyone want to label it as such can perform there own test and can go ahead accordingly.
I am wondering as per UK/EU law do i need to label contain gluten in our ( We do Business to business selling only no retail or direct selling to member of public ) for any product if also I am not selling any product as Gluten free do I need to test for Gluten below 20 ppm or it just not necessary.
Also I have got complete risk assessment for the each product to make sure there is no high risk of any contamination of any listed Allergen as per EU guideline and BRC standard .
Also is it illegal to sell any product with gluten content more then 20 ppm when it is not declared as Gluten free? I am bit confused as we got only one customer who ask for this and I have repeatedly told that we do not guarantee gluten free for our product and for a mix product we also do not test each and every batch for presence of gluten.
Also want to mention , after a complaint of high level of gluten I did a fresh risk assessment for the mix product for each and individual ingredient all the way up to the grower and found no point where there is any direct risk of gluten contamination unless it is grown in the same field as wheat and cross contamination may have occurred which is out of our control .
As we buy products from different countries like turkey, romania , india and china the supplier do not give any conformance that it will be free from gluten not any test result as they do not sell it as gluten free either.
Please suggest me and if anyone got any link for information please pass it .